Haley v London Electricity Board [1965] AC 778

Facts

  • Employees of the London Electricity Board excavated a trench on a public pavement.
  • Lacking materials to properly cordon off the site, the workers placed an upright shovel as a makeshift visual warning near the trench.
  • Mr. Haley, a blind pedestrian, was walking unassisted along the pavement and did not detect the warning.
  • Mr. Haley fell into the unguarded trench and sustained serious injuries.
  • The Board argued that their warning was adequate for sighted individuals and claimed it was not foreseeable that a blind person would be unaccompanied on that pavement.
  • The incident prompted a legal challenge regarding the extent of the duty of care owed to disabled persons in public spaces.

Issues

  1. Whether the London Electricity Board’s duty of care in negligence extended to disabled individuals, specifically blind pedestrians using public pavements unassisted.
  2. Whether the Board could be held liable for breaching this duty by failing to provide warnings accessible to blind individuals.
  3. Whether the risk of injury to blind pedestrians was a reasonably foreseeable consequence of the Board's actions.

Decision

  • The House of Lords held that the duty of care extended to all members of the public, including disabled individuals such as blind pedestrians.
  • The foreseeability of blind or visually impaired people using public sidewalks was affirmed as part of the standard of reasonable care.
  • Providing only a visual warning—an upright shovel—was deemed insufficient, constituting a breach of duty.
  • The Board was found liable for Mr. Haley’s injuries because it failed to consider the risk to disabled individuals who might reasonably be expected to use the pavement.

Legal Principles

  • The standard of care in negligence applies to all foreseeable users of public spaces, including those with disabilities.
  • Reasonable care requires defendants to anticipate and provide for the needs of people with disabilities, rather than serving only the "average" person.
  • Foreseeability must include the presence and requirements of disabled individuals within the general public.
  • A failure to implement accessible precautions where the risk to disabled persons is foreseeable constitutes a breach of duty under negligence law.

Conclusion

Haley v London Electricity Board established that defendants owe a duty of care to all members of the public, including disabled individuals, and must foresee and accommodate their presence in public spaces. The case is a leading authority clarifying that reasonable precautions must address foreseeable risks to individuals with disabilities, shaping subsequent negligence jurisprudence towards greater inclusivity and equity.

The answers, solutions, explanations, and written content provided on this page represent PastPaperHero's interpretation of academic material and potential responses to given questions. These are not guaranteed to be the only correct or definitive answers or explanations. Alternative valid responses, interpretations, or approaches may exist. If you believe any content is incorrect, outdated, or could be improved, please get in touch with us and we will review and make necessary amendments if we deem it appropriate. As per our terms and conditions, PastPaperHero shall not be held liable or responsible for any consequences arising. This includes, but is not limited to, incorrect answers in assignments, exams, or any form of testing administered by educational institutions or examination boards, as well as any misunderstandings or misapplications of concepts explained in our written content. Users are responsible for verifying that the methods, procedures, and explanations presented align with those taught in their respective educational settings and with current academic standards. While we strive to provide high-quality, accurate, and up-to-date content, PastPaperHero does not guarantee the completeness or accuracy of our written explanations, nor any specific outcomes in academic understanding or testing, whether formal or informal.
No resources available.

Job & Test Prep on a Budget

Compare PastPaperHero's subscription offering to the wider market

PastPaperHero
Monthly Plan
$10
Assessment Day
One-time Fee
$20-39
Job Test Prep
One-time Fee
$90-350

Note the above prices are approximate and based on prices listed on the respective websites as of May 2025. Prices may vary based on location, currency exchange rates, and other factors.

Get unlimited access to thousands of practice questions, flashcards, and detailed explanations. Save over 90% compared to one-time courses while maintaining the flexibility to learn at your own pace.

All-in-one Learning Platform

Everything you need to master your assessments and job tests in one place

  • Comprehensive Content

    Access thousands of fully explained questions and cases across multiple subjects

  • Visual Learning

    Understand complex concepts with intuitive diagrams and flowcharts

  • Focused Practice

    Prepare for assessments with targeted practice materials and expert guidance

  • Personalized Learning

    Track your progress and focus on areas where you need improvement

  • Affordable Access

    Get quality educational resources at a fraction of traditional costs

Tell Us What You Think

Help us improve our resources by sharing your experience

Pleased to share that I have successfully passed the SQE1 exam on 1st attempt. With SQE2 exempted, I’m now one step closer to getting enrolled as a Solicitor of England and Wales! Would like to thank my seniors, colleagues, mentors and friends for all the support during this grueling journey. This is one of the most difficult bar exams in the world to undertake, especially alongside a full time job! So happy to help out any aspirant who may be reading this message! I had prepared from the University of Law SQE Manuals and the AI powered MCQ bank from PastPaperHero.

Saptarshi Chatterjee

Saptarshi Chatterjee

Senior Associate at Trilegal